DEPARTMENT OF LABOR
Occupational Safety and Health Administration
Susan Harwood Training Grant Program, FY 2015
AGENCY: Occupational Safety and Health Administration, Labor
ACTION: Notice of availability of funds and funding opportunity announcement (FOA) for Targeted Topic Training Follow-on grants
FUNDING OPPORTUNITY NUMBER: SHTG-FY-15-04
CATALOG OF FEDERAL DOMESTIC ASSISTANCE NUMBER: 17.502
Table of Contents - Susan Harwood Training Grant Program, FY 2015
I. Executive Summary 4
II. Funding Opportunity Description 5
A. Overview of the Susan Harwood Training Grant Program 5
B. Grants Being Announced Under this Funding Opportunity Announcement 5
C. Target Audience and Language 6
III. Project Period and Maximum Funding Levels 6
IV. Eligibility Information 6
A. Eligible Applicants 6
B. Cost Sharing or Matching 7
C. Transparency 7
D. Freedom of Information Act Request (FOIA) 8
E. Non-Viable Applications 9
F. Other Eligibility Requirements 9
G. Special Program Requirements 10
V. Application and Submission Information 10
A. Required Content and Submission Format 11
B. Formatting Requirements 11
C. Application Checklist 12
D. Forms, Assurances, and Certifications 14
E. Application Summary 16
F. Program Abstract 17
G. Technical Proposal 17
1. Problem Statement/Need for Funds 18
a) Target Population 18
b) Topic 18
c) Training and Educational Materials 20
2. Administrative and Program Capability of the Organization 20
a) Training Experience 20
b) Evaluation of Training Activities Experience 20
c) Organizational Chart 21
3. Work Plan 21
a) Work Plan Overview 21
b) Work Plan Activities 21
H. Attachments 31
I. Budget Information 31
1. Budget Information form (SF-424A) 31
2. Detailed Project Budget 32
3. Indirect Cost Allocation Agreement 32
4. Non-federal Resource Contribution 33
5. Evidence of Non-Profit Status 33
6. Funding Allocations, Restrictions, and Guidelines 33
a) Allowable Costs 33
b) Funding Restrictions 34
c) Funding Guidelines 35
d) Subcontracting Opportunities 36
J. Submission Date and Time 36
K. Intergovernmental Review 39
VI. Application Review Information 39
VII. Award Notification Information 39
A. Award Notification and Program Revisions 39
VIII. Post Award Administrative and National Policy Requirements 40
A. Applicable Federal Laws 40
B. Reporting 40
C. Grant Produced Training Materials 40
D. Public Reference to Grant 41
List of Tables
Table 1. Federal Quarters 21
Table 2. Example of Total Number Trained and Contact Hour Projections 27
Appendices
Appendix A – Administrative and Program Cost Information
Appendix B – Procedures for Submitting Electronic Copies of Grant-Funded Materials
The U.S. Department of Labor (DOL), Occupational Safety and Health Administration (OSHA) is soliciting applications from nonprofit organizations for grants to provide training and educational programs for workers and/or employers. Nonprofit organizations, including qualifying labor unions, community-based and faith-based organizations, and employer associations, that are not an agency of a state or local government, are eligible to apply. Indian tribes, tribal organizations, Alaska Native entities, Indian-controlled organizations serving Indians, and Native Hawaiian organizations are eligible to apply in accordance with Executive Order 13175. Additionally, state or local government-supported institutions of higher education are eligible to apply in accordance with OMB 2 CFR 200 and DOL exceptions in 2 CFR 2900. Grants are awarded under Section 21 of the Occupational Safety and Health Act (OSH Act) to provide training and education programs for workers and employers on the recognition, abatement, and prevention of safety and health hazards in the workplace, and to inform workers of their rights and employers of their responsibilities under the OSH Act.
This Funding Opportunity Announcement (FOA) announces the availability of approximately $3.8 million for Susan Harwood Training Grant Program follow-on grants for FY 2014 Targeted Topic Training grantees only. DOL expects to award multiple grants. Only FY 2014 Susan Harwood Targeted Topic Training grantees that have performed satisfactorily are eligible to apply under this funding opportunity announcement.
All information and forms needed to apply for this funding opportunity announcement are published on the http://www.grants.gov Web site (hereinafter “Grants.gov”).
Grants.gov registration must be accurate and up-to-date in Grants.gov and with the System for Award Management (SAM) prior to submitting an application. To remain registered in the SAM database, an applicant is required to review and update registration information at least every 12 months from the date of initial registration. Inaccurate or expired information could result in delays or rejection of the grant application.
DATES: Grant applications must be received electronically by the Grants.gov Web site no later than 11:59 p.m., ET, on Tuesday, June 2, 2015, the application deadline date.
OSHA strongly encourages organizations to submit the grant application in sufficient time to ensure that the application has been received and successfully validated by Grants.gov by the application deadline.
SUBMITTAL INFORMATION: Applications for grants submitted under this competition must be submitted electronically using the government-wide Grants.gov Web site at: http://www.grants.gov. If applying online poses a hardship, applicants must contact the OSHA Directorate of Training and Education office listed in this announcement at least four weeks prior to the application deadline date, 11:59 p.m., ET, on Tuesday, June 2, 2015, to speak to a representative who can provide assistance to ensure that applications are submitted online by the closing date. Requests for extensions to this deadline will not be granted. Further information regarding submitting a grant application electronically can be found in Section V.J.2.
FOR FURTHER INFORMATION CONTACT: Questions regarding this funding opportunity announcement should be emailed to [email protected] or directed to Jason Rasmussen, Program Analyst, or Kimberly Mason, Director, Office of Training Programs and Administration, at 847-759-7700 (note this is not a toll-free number). Personnel will not be available after 5:00 p.m., ET, on the application deadline date, to answer questions. To obtain further information on the Susan Harwood Training Grant Program, visit the OSHA Web site at: http://www.osha.gov/dte/sharwood/index.html.
Questions regarding Grants.gov should be emailed to [email protected] or directed to the Grants.gov Contact Center, at 1-800-518-4726 (toll free number). The Contact Center is available 24 hours a day, 7 days a week. The Contact Center is closed on federal holidays.
The Susan Harwood Training Grant Program provides funds for non-profit organizations to develop training materials and train workers and/or employers to recognize, abate, and prevent safety and health hazards in their workplaces and provide related assistance. The program emphasizes seven areas:
Training workers and/or employers on identifying and means of preventing serious safety and health hazards identified by OSHA through the DOL’s Strategic Plan, as part of an OSHA special emphasis program, or other OSHA priorities (see www.osha.gov).
Educating workers on their rights and educating employers on their responsibilities under the OSH Act.
Educating workers and/or employers in small businesses. For purposes of this grant program, a small business is one with 250 or fewer employees.
Training workers and/or employers about new OSHA standards.
Training at-risk and/or low-literacy worker populations. This includes temporary workers.
Developing and disseminating materials to train and educate workers.
Under this funding opportunity announcement, OSHA will accept applications for Targeted Topic Training Follow-on Grants from FY 2014 Targeted Topic Training grantees only.
Targeted Topic Training grants develop and conduct quality training for workers of multiple employers, and where appropriate, develop quality safety and health training and educational materials addressing safety and health hazards associated with one of the OSHA selected training topics listed in Section V.G.1.b). Technical assistance may be proposed in addition to the training. Applicants will be expected to conduct a significant number of training programs addressing occupational safety and health hazards identified by OSHA.
Training materials developed and/or training conducted must serve multiple employers.
All training materials developed and/or training conducted must serve multiple employers and workers in one or more of the following target audiences:
small businesses (less than 250 employees)
new businesses
limited English proficiency workers
non-literate and low literacy workers
young workers
temporary workers
minority and other hard-to-reach workers
workers in high-hazard industries and industries with high fatality rates
Training must be conducted in both a language and vocabulary that the participants can understand.
Special consideration will be given to grant proposals that include training materials and training programs for limited English proficiency workers, including Spanish, and Asian American and Pacific Islander languages.
The maximum funding level is not to exceed 90% of the applying organization’s FY 2014 grant award for the 12-month project performance period for organizations that received a new Targeted Topic Training grant in FY 2014.
All grants in this funding opportunity announcement will be awarded for a 12-month project performance period. The 12-month project period for these grants begins no later than September 30, 2015. There is approximately $3.8 million in funding that will be available for FY 2015 Susan Harwood Targeted Topic Training Follow-on grants in FY 2015.
Only FY 2014 Susan Harwood Targeted Topic Training grantees that have performed satisfactorily are eligible to apply under this funding opportunity announcement.
Applicants are not required to contribute non-federal resources.
DOL is committed to conducting a transparent grant award process and publicizing information about program outcomes. Posting grant applications on public Web sites is a means of promoting and sharing innovative ideas. For this grant competition, DOL will publish the Program Abstract required by Section V.F. and selected information from the SF-424, Application for Federal Assistance, for all applications on the Department’s public Web site, http://www.dol.gov/dol/grants/. Additionally, DOL will publish a version of the Technical Proposal required by Section V.G., for all those applications that are awarded grants, on the Department’s Web site, http://www.dol.gov/dol/grants/. Except for the Program Abstract, none of the Attachments to the Technical Proposal will be published. The Technical Proposals and Program Abstracts will not be published until after the grants are awarded. In addition, information about grant progress and results may also be made publicly available.
DOL recognizes that grant applications sometimes contain information that an applicant may consider proprietary or business confidential information, or may contain personally identifiable information. Proprietary or business confidential information is information that is not usually disclosed outside an organization and disclosing this information is likely to cause the organization substantial competitive harm.
Personally identifiable information is any information that can be used to distinguish or trace an individual‘s identity, such as name, Social Security Number, date and place of birth, mother‘s maiden name, or biometric records; and any other information that is linked or linkable to an individual, such as medical, educational, financial, and employment information.1
Program Abstracts will be published in the form originally submitted, without any redactions. Applicants should not include any proprietary or confidential business information or personally identifiable information in this summary. In the event that an applicant submits proprietary or confidential business information or personally identifiable information, DOL is not liable for the posting of this information contained in the Program Abstract. The submission of the grant application constitutes a waiver of the applicant’s objection to the posting of any proprietary or confidential business information contained in the Program Abstract. Additionally, the applicant is responsible for obtaining all authorizations from relevant parties for publishing all personally identifiable information contained within the Program Abstract. In the event the Program Abstract contains proprietary or confidential business or personally identifiable information, the applicant is presumed to have obtained all necessary authorizations to provide this information and may be liable for any improper release of this information.
By submission of this grant application, the applicant agrees to indemnify and hold harmless the United States, the U.S. Department of Labor, its officers, employees, and agents against any liability or for any loss or damages arising from this application. By such submission of this grant application, the applicant further acknowledges having the authority to execute this release of liability.
To ensure that proprietary or confidential business information or personally identifiable information is properly protected from disclosure when DOL posts the winning Technical Proposals, applicants whose Technical Proposals will be posted will be asked to submit a second redacted version of the Technical Proposals, with any proprietary or confidential business information and personally identifiable information redacted. All non-public information about the applicant’s and consortium members’ staff (if applicable) should be removed as well.
The Department will contact the applicants whose Technical Proposals will be published by letter or email and provide further directions about how and when to submit the redacted version of the Technical Proposal.
Submission of a redacted version of the Technical Proposal will constitute permission by the applicant for DOL to make the redacted version publicly available. DOL will also assume that by submitting the redacted version of the Technical Proposal, the applicant has obtained the agreement to the applicant’s decision about what material to redact of all persons and entities whose proprietary, confidential business information or personally identifiable information is contained in the Technical Proposal. If an applicant fails to provide a redacted version of the Technical Proposal by the date requested in the instruction letter or email, DOL will publish the original Technical Proposal in full, after redacting only personally identifiable information. (Note that the original, unredacted version of the Technical Proposal will remain part of the complete application package, including an applicant’s proprietary and confidential business information and any personally identifiable information.)
Applicants are encouraged to maximize the grant application information that will be publicly disclosed, and to exercise restraint and redact only information that clearly is proprietary, confidential commercial/business information, or capable of identifying a person. The redaction of entire pages or sections of the Technical Proposal is not appropriate and will not be allowed, unless the entire portion merits such protection. Should a dispute arise about whether redactions are appropriate, DOL will follow the procedures outlined in the Department’s Freedom of Information Act (FOIA) regulations (29 CFR Part 70).
Redacted information in grant applications will be protected by DOL from public disclosure in accordance with federal law, including the Trade Secrets Act (18 U.S.C. § 1905), FOIA, and the Privacy Act of 1974 (5 U.S.C. § 552a). If DOL receives a FOIA request for an application, the procedures in DOL’s FOIA regulations for responding to requests for commercial/business information submitted to the government will be followed, as well as all FOIA exemptions and procedures, 29 CFR § 70.26. Consequently, it is possible that application of FOIA rules may result in release of information in response to a FOIA request that an applicant redacted in its redacted copy.
Applications that fail to satisfy the requirements stated below may be considered non-viable and not be given further consideration.
Applications are required to be submitted electronically through Grants.gov as specified in Section V.J.2. Applications not submitted electronically through Grants.gov will not be considered.
Applications must be submitted on or before 11:59 p.m., ET, on the due date as specified in Section V.J.1. Applications that do not receive a date/time-stamp email indicating application submission on or before 11:59 p.m., ET, on the due date, will be considered non-viable and will not be given further consideration.
Applications must be successfully validated by Grants.gov as specified in Section V.J.3. Applications that are not successfully validated by Grants.gov because the submission was not approved by the Authorized Organization Representative (AOR), or the organization does not have a current registration with the System for Award Management (SAM) at the time of application submission, will be considered non-viable and will not be given further consideration.
Applications must provide current proof of nonprofit status as outlined in Section V.I.5, with the exception of institutions of higher education. Applications that do not provide proof of nonprofit status may be considered non-viable and may not be given further consideration.
Applications must contain all of the required forms and documents identified in Section V.C., Application Checklist. Applications that do not contain all of the required forms and documents may be considered non-viable and may not be given further consideration.
Applications must propose only training based on one of the identified OSHA selected topics in this funding opportunity announcement as outlined in Section VI.F.1.c). Applications that propose training that does not align with one of the identified OSHA selected topics will be considered non-viable and will not be given further consideration.
All grantees must comply with legal rules pertaining to inherently religious activities by organizations that receive federal financial assistance. The U.S. Government is generally prohibited from providing direct financial assistance for inherently religious activities. In this context, the term direct financial assistance means financial assistance that is provided directly by a government entity or an intermediate organization, as opposed to financial assistance that an organization receives as the result of the genuine and independent private choice of a beneficiary. In other contexts, the term “direct financial assistance” may be used to refer to financial assistance that an organization receives directly from the federal government (also known as “discretionary” assistance), as opposed to assistance that it receives from a state or local government (also known as “indirect” or “block” grant assistance). The term “direct” has the former meaning throughout this funding opportunity announcement.
The grantee may be a faith-based organization or work with and partner with religious institutions; however, “direct” federal assistance provided under grants with the U.S. DOL must not be used for religious instruction, worship, prayer, proselytizing, or other inherently religious practices. 29 CFR Part 2, Subpart D governs the treatment in DOL government programs of religious organizations and religious activities; the grantee and any sub-contractors are expected to be aware of and observe the regulations in this subpart.
DOL may require that the program or project participate in an evaluation of overall performance of the Harwood grants and/or impacts on participants. Therefore, as a condition of award, the grantee is required to cooperate with any evaluation of the program DOL may undertake. This cooperation may include but is not limited to site visits, collection of programmatic administrative and performance data, and interviews with grant program personnel and program participants.
All information needed to apply for this funding opportunity is referenced as part of this announcement, and all forms are available on the Grants.gov Web site.
Organizations will only be awarded one Susan Harwood grant per fiscal year, including follow-on grants:
Capacity Building Development;
Capacity Building Pilot;
Targeted Topic Training; or
Targeted Topic Training and Educational Material Development.
OSHA encourages the training of different workers each year. If an organization is awarded a grant for consecutive years to provide training on the same topic to a target population, the organization must show in its work plan a process to ensure that different workers will be trained, than received training in the previous year.
An organization can operate no more than one Susan Harwood grant in any given fiscal year. A new proposal under this announcement will not be considered if a current grantee is awarded more than a three-month no-cost time extension on an active grant.
A grant application must be submitted electronically through the http://www.grants.gov Web site. The application must contain all of the required information as outlined in Section V.C., Application Checklist, to be considered responsive to this funding opportunity announcement. The application must be divided into major sections and sub-sections and clearly identified. Forms are available through: http://www.grants.gov and must be submitted electronically as a part of the grant application. Each Grants.gov application package has a cover sheet that contains instructions on how to open and use the forms in the application package. The Susan Harwood grant application package at http://www.grants.gov contains a menu of “Mandatory Documents” which must be completed and submitted online. The menu of “Mandatory Documents” can only be located after opening the grant package. A description of the application evaluation process is provided in Section VI.
All applicants for federal grants and funding opportunities are required to have a Data Universal Number System (DUNS) number, and must supply the DUNS number on the SF-424. The DUNS number is a nine-digit identification number that uniquely identifies business entities. For additional information or to obtain a DUNS number visit the Web site at: http://fedgov.dnb.com/webform/.
Registration information with Grants.gov and System for Award Management (SAM) must be accurate and up-to-date prior to submitting an application. To remain registered in the SAM database, an applicant is required to review and update registration information at least every 12 months from the date of initial registration. Inaccurate or expired information could result in delays or rejection of the grant application.
All application materials must be submitted in 8 ½” x 11” format on white paper with one-inch margins. Application summaries, abstracts, technical proposals, etc., must be double-spaced format in 12-point font.
If an application exceeds the cited page limitation for double-spaced pages in the technical proposal, the extra pages will not be reviewed. In addition, if a technical proposal is single-spaced and/or one-and-a-half spaced (in whole or in part) the total number of these lines will be doubled. This adjustment may result in an increased total number of pages. The extra pages will not be reviewed. Only graphs and numerical tables as part of the technical proposal may be single-spaced.
Attachments should be submitted in the order specified in Section V.C., Application Checklist. Please use the file naming nomenclature where indicated, and the checklist title if it is not indicated. File attachment names should be no longer than 50 characters to avoid submission and processing errors. Applicants are limited to using the following characters in all attachment file names: A-Z, a-z, 0-9, underscore (_), hyphen (-), parenthesis (()), curly brackets ({}), square brackets ([]), tilde (~), exclamation point (!), comma (,), dollar sign ($), percent sign (%), plus sign (+), equal sign (=), space, and period. While Grants.gov may accept more characters, DOL E-Grants may not accept characters other than what is listed above. Use the appropriate characters to ensure OSHA can view the file attachments.
Text documents, including the application summary, program abstract and technical proposal, should be submitted in Microsoft Office format. Forms, assurances, and certifications should be submitted in Adobe Reader (PDF) format. Files must not be locked or protected.
Applicants may use the checklist below as a guide when preparing the application package. All required documents on the Application Checklist below must be submitted by the application due date and time specified in Section V.J.1.
Forms found on the Grants.gov Forms tab are for information only and cannot be submitted with the grant application package. When applying for a grant, the application package must be downloaded; the forms within the application package must be completed and submitted it in their entirety.
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What to Submit |
Where Found |
How to Submit |
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SF-424 – Application for Federal Assistance |
Referenced in Section V.D.1. and found at Grants.gov Forms Repository at: http://www.grants.gov/web/grants/forms/sf-424-family.html. |
This is a required form and is downloaded with the grant application package. It must be completed and uploaded as part of the grant application. |
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SF-424A – Application for Federal Assistance |
Referenced in Section V.D.2. and found at Grants.gov Forms Repository at: http://www.grants.gov/web/grants/forms/sf-424-family.html. |
This is a required form and is downloaded with the grant application package. It must be completed and uploaded as part of the grant application. |
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SF-424B – Assurances – Non-Construction Programs |
Referenced in Section V.D.3. and found at Grants.gov Forms Repository at: http://www.grants.gov/web/grants/forms/sf-424-family.html. |
This is a required form and is downloaded with the grant application package. It must be completed and uploaded as part of the grant application. A detailed project budget must be completed in addition to the SF-424A Form. |
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Combined Assurance Form (ED 80-0013) |
Referenced in Section V.D.4. and found at Grants.gov Forms Repository at: http://www.grants.gov/web/grants/forms/sf-424-family.html. |
This is a required form and is downloaded with the grant application package. It must be completed and uploaded as part of the grant application. |
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Project/Performance Site Location(s) |
Referenced in Section V.D.5. and found at Grants.gov Forms Repository at: http://www.grants.gov/web/grants/forms/sf-424-family.html. |
This is a required form and is downloaded with the grant application package. It must be completed and uploaded as part of the grant application. |
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SF-LLL – Disclosure of Lobbying Activities |
Referenced in Section V.D.6. and found at Grants.gov Forms Repository at: http://www.grants.gov/web/grants/forms/sf-424-family.html. |
This is a required form only when the applicant meets the requirements in the Combined Assurance Form. If required, it must be completed and uploaded as part of the grant application. |
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Application Summary |
Referenced in Section V.E. of the announcement under “Application Summary.” |
This is a required document and must be created by the applicant organization. The application summary must be uploaded as an attachment to the grant application. |
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Program Abstract |
Referenced in Section V.F. of the announcement under “Program Abstract.” |
This is a required document and must be created by the applicant organization. The program abstract must be uploaded as an attachment to the grant application. |
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Technical Proposal |
Referenced in Section V.G. of the announcement under “Technical Proposal.” |
This is a required document and must be created by the applicant organization. The technical proposal must be uploaded as an attachment to the grant application. |
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Organizational Chart |
Referenced in Section V.G.2.c) of the announcement under “Organizational Chart.” |
This is a required document and must be created by the applicant organization. The organizational chart must be uploaded as an attachment to the grant application. |
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Detailed Project Budget |
Referenced in Section V.I.2. of the announcement under “Detailed Project Budget.” |
This is a required document and must be created by the applicant organization. The detailed project budget must be completed in addition to the SF-424A Form. The detailed project budget must be uploaded as an attachment to the grant application. |
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Indirect Cost Allocation Agreement |
Referenced in Section V.I.3. of the announcement under “Indirect Cost Allocation Agreement.” |
This is a required document only when the applicant has an indirect cost allocation agreement with a cognizant agency. If required, it must be completed and uploaded as part of the grant application. |
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Evidence of Non-Profit Status |
Referenced in Section V.I.5. of the announcement under “Evidence of Non-Profit Status.” |
Applicants must submit one of the documents specified in Section V.I.5. as current evidence of non-profit status. Evidence of Non-Profit Status must be uploaded as an attachment to the grant application. |
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Non-federal Resource Contribution |
Referenced in Section V.I.4. of the announcement under “Non-federal Resource Contribution.” |
This is a required document only when the applicant is including non-federal resource contribution as part of the grant application. The non-federal resource contribution must be created by the applicant organization and must be uploaded as an attachment to the grant application. |
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Other Attachments |
Referenced in Section V.H. of the announcement under “Other Attachments.” |
Applicant organizations are welcome to submit additional attachments but they are not required as part of the grant application. If included, organizations are limited to a maximum of 20 pages. Other attachments must be uploaded as an attachment to the grant application. |
Applicants seeking financial assistance under this funding opportunity announcement must submit the first five forms listed and described below. The sixth form, which relates to the disclosure of lobbying activities, may also be required as described below. All of the following forms are part of the Grants.gov application package:
SF-424 Application for Federal Assistance;
SF-424A Budget Information – Non-Construction Programs;
SF-424B Assurances – Non-Construction Programs;
Combined Assurances Form (ED-80-0013);
Project/Performance Site Location; and
SF-LLL Disclosure of Lobbying Activities.
The SF-424 Application for Federal assistance must clearly identify the applicant and must be signed by the individual with the authority to enter into the grant agreement. The government may elect to award the grant(s) with or without negotiations with the applicant. Should a grant be awarded without negotiations, the award will be based on the applicant’s signature on the SF-424, including electronic signature via E-Authentication on http://www.grants.gov, which constitutes a binding offer by the applicant. As stated in block 21 of the SF-424 Form, signature of the Authorized Representative on the SF-424 certifies to the statements contained in the certifications, the required assurances are provided, and the organization agrees to comply with any resulting terms if an award is accepted.
A detailed description is provided in Section V.I.1.
Electronic signature on the Grants.gov application provides assurances to comply with federal laws, executive orders, regulations, and policies governing this program.
This form covers the lobbying certificate as required by 31 U.S.C. § 1352, and implemented at 34 CFR Part 82, for persons entering into a grant or cooperative agreement over $100,000, as defined at 34 CFR Part 82, Sections 82.105 and 82.110; the debarment, suspension and other responsibility matters certification as required by Executive Order 12549, Debarment and Suspension, and implemented at 34 CFR Part 85, for prospective participants in primary covered transactions, as defined at 34 CFR Part 85, Sections 85.105 and 85.110; and drug-free workplace certification as required by the Drug-Free Workplace Act of 1988, and implemented at 34 CFR Part 85, Subpart F, for grantees, as defined at 34 CFR Part 85, Sections 85.605 and 85.610.
Applicants should include as many site locations as known at the time of application. Please note that this standard form is used for many programs and has a check box for applying as an individual. Disregard this box since individuals are not eligible to apply to this announcement.
This disclosure form is only required when an organization makes payment to any lobbying entity for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with a covered federal action.
The Application Summary must be submitted in 8 ½” x 11” format on white paper and is not to exceed two double-spaced, 12-point font, typed pages with one-inch margins. The document file should be saved in Microsoft Word format. The file must not be locked or protected. The file name of the document should mimic the following nomenclature:
Organization Name Application Summary.doc
or
Organization Name Application Summary.docx
The Application Summary must include the following sections:
Applicant organization’s full legal name as listed on the Application for Federal Assistance (SF-424) in Section 8a.
Project Director’s name, title, street address for overnight delivery service, and mailing address if it is different from the street address, telephone and fax numbers, and email address. The Project Director is the person who will be responsible for the day-to-day operation and administration of the program. The Project Director’s name must be the same name listed on the Application for Federal Assistance Form (SF-424) in Section 8f: name and contact information of person to be contacted on matters involving this application.
Authorized Representative/Certifying Representative’s name, title, street address for overnight delivery service, mailing address if it is different from the street address, telephone and fax numbers, and email address. An Authorized Representative/Certifying Representative is the official in the organization authorized to enter into grant agreements. The Authorized Representative/Certifying Representative’s name must be the same name listed on the Application for Federal Assistance Form (SF-424) in Section 21 for Authorized Representative.
Financial Certifying Representative’s name, title, street address for overnight delivery service, mailing address if it is different from the street address, telephone and fax numbers, and email address. The Financial Certifying Representative will be authorized by the organization to submit and sign off on the Federal Financial Report Form (SF-425), which is submitted quarterly during the grant period, as per Section V.G.3.b)(5)(b)(ii).
Funding Amount. List the amount of federal funding being requested to perform work plan and administrative activities for the 12-month project performance period. Section III. describes the maximum funding limits. If the organization is contributing non-federal resources, list the amount and source of non-federal funds. These amounts should be consistent with the amounts listed on the Application for Federal Assistance Form (SF-424).
Grant Category. All applicants must indicate the grant category as Targeted Topic Training Follow-on.
Grant Topic. List occupational safety and health training topic(s) to be addressed by the grant. Applicants should indicate an OSHA topic from Section V.G.1.b).
Target Audience. Indicate the target audiences to be served, as listed in Section II.C.
Affiliations. Please list the organization’s relationship to a parent organization, if applicable, and any affiliations with other organizations that are included in the application.
Congressional Districts. Please include the Congressional District in which the organization resides. If possible, please include those in which training is proposed and/or materials will be disseminated. The Congressional Districts must be the same as those listed on the Application for Federal Assistance Form (SF-424) in Section 16 for Congressional Districts.
Provide a brief abstract of the proposed grant. The program abstract must be submitted in 8 ½” x 11” format on white paper and is not to exceed one double-spaced, 12-point font, typed page with one-inch margins. The document file should be saved in Microsoft Word format. The file must not be locked or protected. The file name of the document should mimic the following nomenclature:
Organization Name Program Abstract.doc
or
Organization Name Program Abstract.docx
The abstract should include the organization’s name, grant category, target audience, proposed occupational safety and health training topic(s), key grant activities, and geographical areas that will be impacted.
The Technical Proposal must be submitted in 8 ½” x 11” format on white paper and is not to exceed 20 double-spaced, 12-point font typed pages with one-inch margins. The document file should be saved in Microsoft Word format. The file must not be locked or protected. The file name of the document should mimic the following nomenclature:
Organization Name Technical Proposal.doc
or
Organization Name Technical Proposal.docx
The document must address each section listed below.
A problem statement, including the need for funding, should be included in each grant application. Clearly describe the following in the problem statement.
Describe the target population (Section II.C.), the target population’s geographic location(s), including state(s), and the barriers that have prevented this population from receiving adequate training.
Targeted Topic Training Follow-on applicants are required to continue training on the same OSHA selected topics in the FY 2014 grant. In addition, all trainings must include information regarding employer responsibilities and worker rights under the OSH Act, including the right to raise health and safety concerns free from retaliation. All applicants must provide training on the anti-retaliation provisions under Section 11(c) of the OSH Act, including employee rights and employer responsibilities, additional whistleblower laws enforced by OSHA as applicable, and whistleblower complaint procedures (including required time constraints).
Applicants who choose to address more than one topic must:
Include a detailed justification narrative explaining how multiple topics have been selected.
Describe how the topics complement each other and benefit the proposed target audience.
Describe how the combination of topics will add greater value to the training materials being developed and/or training conducted for the proposed target audience than if it was a single topic.
Note: To avoid “double-counting,” training numbers for grants with multiple topics will be counted for each time the body of training materials developed under the grant is presented to a group of students; topics will not be counted separately.
Describe the types of training and educational materials to be developed and/or obtained. Applicants should not propose the development of training or educational materials that duplicate existing material. The purpose is to produce quality training and educational materials that fill an unmet need and have broad applicability. A detailed description of the training materials, including training objectives, training topics, and source of training materials (if obtaining) should be included as part of Section V.G.3.b)(1). Existing Susan Harwood training materials can be accessed at: http://www.osha.gov/dte/grant_materials/index.html. Materials feature various topics and languages, and include items such as PowerPoint presentations, instructor guides, student manuals, student exercises, and tests.
Briefly describe the organization’s functions and activities. Relate this description of functions to the organizational chart included in the application, as discussed below.
Describe the organization’s experience conducting the training being proposed, including experience working with the target audience. Include program specifics such as program titles, the type(s) of training materials developed, the number of trainee contact hours provided, and the numbers trained under the current FY 2014 grant.
Describe the organization’s experience conducting evaluations of training activities and the levels of training evaluations conducted under the current FY 2014 grant, as it relates to the evaluations described in Section V.G.3.b)(4).
Include an organizational chart of the staff that will be working on the grant and their positions within the applicant organization. Indicate any new staff position(s) that have been added as a part of the FY 2014 award, and any new positions that are proposed as part of the applicant’s work plan.
Develop a 12-month work plan that is broken out by federal calendar year quarters as shown in Table 1.
Table 1. Federal Quarters
Federal Quarter |
Time Span |
Quarter 1 |
October 1 to December 31 |
Quarter 2 |
January 1 to March 31 |
Quarter 3 |
April 1 to June 30 |
Quarter 4 |
July 1 to September 30 |
An outline of specific items required in the work plan follows.
The work plan must describe the plan for grant activities and the anticipated outcomes for the 12-month project period. The overall work plan must describe planned project components, such as the development of training materials or the plan to use existing training materials, if not already complete, the training content, the number of trainees and the number of contact hours per trainee for each training program being proposed, recruiting of trainees, where or how training will take place, and the anticipated benefits to workers and/or employers receiving the training. Also describe planned activities relating to conducting Level 1 and 2 training evaluations.
The overall plan should be broken down into activities or tasks. For each activity, explain what will be done, who will do it, when it will be done, and the planned results of the activity.
Describe all training and educational materials to be produced under the grant, if proposed, and provide a timetable for developing and producing the materials. The statement should address how the proposed training and educational materials fill an unmet need and that they have broad applicability. Applicants should not propose the development of training or educational materials that duplicate existing training materials. OSHA posts training materials developed by previous grantees on its public Web site. These materials feature various topics and languages, and include items such as PowerPoint presentations, instructor guides, student manuals, student exercises and tests. Materials previously developed by Susan Harwood grantees can be accessed at: http://www.osha.gov/dte/grant_materials/index.html.
Grantees must follow all copyright laws and provide written certification that materials are free from copyright infringements. If training will be conducted with training materials approved by OSHA during the FY 2014 performance period, and no additional training materials will be developed or incorporated into the proposed 12-month performance period, the applicant should state such.
Grantees are expected to follow the guidance provided in the OSHA publication entitled “Best Practices for the Development, Delivery, and Evaluation of Harwood Training Grants” [OSHA 3686-09 2010]. The document addresses needs assessments, proven adult learning techniques, effective models for worker training, and training evaluation documentation. A copy of the publication can be downloaded at http://www.osha.gov/dte/sharwood/best-practices.html.
If new training and educational materials will be developed during the 12-month performance period, the applicant will be expected to submit classroom quality products that follow the commonly accepted Instructional Systems Design (ISD) process that OSHA has adopted as a quality measure for all of its education and training products. The five ISD steps are: analysis, design, development, implementation, and evaluation. Provide a timetable for developing, evaluating, validating and producing the material. Validation should include at least one training session for content feedback and content revision. More information on the ISD process can be found http://www.nwlink.com/~donclark/hrd/sat.html.
Applicants can revise existing Susan Harwood grant materials or obtain training materials from a third party. Existing Susan Harwood grant materials are available at: http://www.osha.gov/dte/grant_materials/index.html. Obtained materials should have been developed under commonly accepted instructional design processes.
The training materials must address the recognition, abatement, and prevention of safety and health hazards. Training materials (obtained or developed) must include information regarding worker rights under OSHA law, including the right to file a complaint free from discrimination and the elements for a valid complaint. If an organization plans to develop training materials for training workers or employers or to train workers or employers in any of the 27 states operating OSHA-approved State Plans, state OSHA requirements for that state must be included in the training materials.
The training materials must include information on the whistleblower protection provisions that OSHA administers under Section 11(c) of the OSH Act. Training materials should cover employer and employee rights and responsibilities, whistleblower laws enforced by OSHA, and OSHA’s Complaint Investigation Procedures. See http://www.whistleblowers.gov/ for additional information.
Organizations proposing to develop materials and/or deliver training in languages other than English must provide an English version of the materials. Organizations proposing to develop Spanish-language training materials must utilize the OSHA Dictionaries (English-to-Spanish and Spanish-to-English) for terminology. The dictionaries are available on the OSHA Web site at http://www.osha.gov/dcsp/compliance_assistance/spanish_dictionaries.html. The English version of the materials must be approved by OSHA prior to translation.
All training materials must be reviewed and approved (e.g., promotional flyers, advertising, training materials, evaluation instruments) for technical accuracy and suitability of content before the materials may be used. Therefore, the timetable must include provisions for an OSHA review of both draft and final products. Allow two to three weeks for an OSHA review of draft materials. Any changes to the training and educational materials, at any time during the grant period, must be reviewed and approved by OSHA before use.
All training and educational materials developed or used by grantees will be required to be updated to reflect any changes to OSHA standards and policies that occur during the performance period. This includes any materials that may have been previously approved by OSHA.
Any training materials created under a prior-year grant and subsequently updated must be reviewed and approved by OSHA (all changes to the materials should be highlighted). Any changes to the training and educational materials, at any time during the grant period, must be reviewed and approved by OSHA before use. If no changes to OSHA standards or policies occurred since the educational materials were last approved by OSHA, and no other changes were made by the grantee, the materials do not need to be reviewed.
Two (2) electronic and two (2) hard-copies of the materials are to be submitted to OSHA prior to or along with the close-out report. Electronic copies should be submitted per the Grant-Funded Material Submittal Procedures outlined in Appendix B.
Any applicant proposing online training must produce training materials that are compliant with Section 508 of the Rehabilitation Act of 1973, as amended http://www.section508.gov/Section-508-Of-The-Rehabilitation-Act. Specific compliance checklists can be found at http://www.hhs.gov/web/508/checklists/index.html.
In all circumstances, all approved grant-funded materials developed by a grantee shall contain the following disclaimer:
This material was produced under grant number _____________ from the Occupational Safety and Health Administration, U.S. Department of Labor. It does not necessarily reflect the views or policies of the U.S. Department of Labor, nor does mention of trade names, commercial products, or organizations imply endorsement by the U.S. Government.
The recruiting plan should include what methods the applicant plans to utilize to recruit workers from the target audience for the proposed training. Past success in reaching the target audience as well as any plans to work with other organizations during the recruiting efforts should be described in detail. All materials developed for recruiting must be reviewed and approved by OSHA.
When describing the proposed occupational safety and health training, include the topics to be taught, the projected number of trainees, and the number of contact hours per trainee for each proposed training course, the proposed training sites (classroom, worksites), and their geographical locations.
OSHA encourages the training of different workers each year. If an organization is awarded a grant for consecutive years to provide training on the same topic to a target population, the organization must show in its work plan a process to ensure that different workers will be trained, than received training in the previous year.
Training must include training on the required training and educational material content as indicated in Section V.G.1.b).
The Susan Harwood Training Grant Program’s primary focus is worker-level training. Training should be designed as a minimum of 1/2 hour and a maximum of 7 1/2 contact hours per day, for every day of training.
Contact hours include instructor-led contact minutes used to train on the training learning objectives. Instructor-led minutes used for administrative activities such as presenting training certificates cannot be counted toward the contact hours. Break time and lunchtime cannot be counted toward the contact hours.
Training should be limited to eligible trainees. Eligible trainees are those workers that are currently covered under the OSH Act of 1970, SEC. 4, codified at 29 U.S.C. 653.
OSH Act of 1970, SEC. 4. Applicability of This Act |
(a) This Act shall apply with respect to employment performed in a workplace in a State, the District of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, American Samoa, Guam, the Trust Territory of the Pacific Islands, Wake Island, Outer Continental Shelf Lands defined in the Outer Continental Shelf Lands Act, Johnston Island, and the Canal Zone. The Secretary of the Interior shall, by regulation, provide for judicial enforcement of this Act by the courts established for areas in which there are no United States district courts having jurisdiction. |
(b) (1) Nothing in this Act shall apply to working conditions of employees with respect to which other Federal agencies, and State agencies acting under section 274 of the Atomic Energy Act of 1954, as amended (42 U.S.C. 2021), exercise statutory authority to prescribe or enforce standards or regulations affecting occupational safety or health. |
In addition, currently unemployed persons that plan to return to or are about to enter the workforce in a position that is covered by the OSH Act may be trained. Some state and local governments are not covered under the OSH Act.
The specific methodology for projecting trainee numbers must be described.
To facilitate participatory learning, the recommended class size is from 10 to 30 trainees. The recommended minimum and maximum limits are from 3 to 40 trainees per training.
All training should be participatory in nature and actively involve workers in the training, including using the methods described in OSHA’s document entitled ”Best Practices for the Development, Delivery, and Evaluation of Susan Harwood Training Grants” [OSHA 3686-09 2010]. A copy of the publication can be downloaded at http://www.osha.gov/dte/sharwood/best-practices.html. Please include specific details regarding how participatory learning will be achieved.
Train-the-trainer training may be proposed under this grant announcement, but is not required. To ensure that training provided to trainers is subsequently used to train workers (second tier training), a plan to conduct second tier training directly to workers must be included as outlined below.
Only one level of train-the-trainer training may be proposed. In other words, the trainers trained as part of these grant activities can only train workers (second tier training); not additional levels of trainers.
If the proposal contains a train-the-trainer component, the following information must be provided:
Specify the type of ongoing support the grantee will provide to new trainers.
Specify the worker population that the new trainers will train.
If the newly trained trainers will provide training to workers under the work plan for this grant period, estimate the number of courses to be conducted for workers by the new trainers during the grant period.
The applicant must include a description of how the organization will obtain data, via a reporting system, from the new trainers to document the second tier training during the grant period. The description should include a system whereby training documentation (sign-in sheets, training agenda, course evaluations, etc.) and trainee numbers are submitted to the applying organization within a short time after the completed training.
All of the above information must be included in the application for the train-the-trainer component to be evaluated.
Describe the training to be conducted and quantify the projected total number trained and projected total contact hours. Include the following items:
Describe the target audience(s) (Section II.C.) for each proposed type of training.
Identify the type(s) of training that will be conducted: worker, train-the-trainer, or employer.
Describe how each type of training will reach multiple employers and/or their workers.
Indicate the projected number trained (workers and/or employers) per type of training and target audience (Section V.G.3.b)(3)).
Indicate the number of contact hours for each type of training (workers, train-the-trainer, and/or employer) and target audience (Section II.C.). Training contact hours are defined in Section V.G.3.b)(3)(b). See Table 2 as an example.
Substantiate the methodology used to develop the projections for total number trained and total contact hours for each type of training (train-the-trainer, worker, or employer).
Table 2. Example of Total Number Trained and Contact Hour Projections
Audience |
Type of Training |
Length of training (contact hours) |
Projected Number Trained |
Total Contact hours per training * |
Temporary Worker |
Worker |
4 |
500 |
2,000 |
Hard-to-Reach Worker Limited English Proficiency/ Low Literacy |
Worker |
2 |
300 |
600 |
Hard-to-Reach Worker Limited English Proficiency/ Low Literacy |
Train-the Trainer |
8 |
10 |
80 |
Small Business |
Employer |
5 |
30 |
150 |
Total |
|
|
840 |
2,830 |
*Total contact hours per training = (length of training x projected number trained)
Constitution Day and Citizenship Day is required of educational institutions only. These activities should be addressed in the work plan. Section 111 of Division J of Public Law 108-447, the “Consolidated Appropriations Act, 2005,” December 8, 2004; 118 Stat. 2809, 3344-45, requires “educational institutions” that receive federal funds to hold an educational program on the United States Constitution on September 17 (“Constitution Day and Citizenship Day”) of each fiscal year for which the institution receives funds. The Office of Personnel Management has placed relevant materials on its Web site at the following address: http://archive.opm.gov/constitution_initiative/. The U.S. Department of Education’s Federal Register Notice of the Implementation of Constitution Day and Citizenship Day on September 17 of Each Year, published on May 24, 2005, can be found at: http://www.gpo.gov/fdsys/pkg/FR-2005-05-24/pdf/05-10355.pdf. Please note that this Web site primarily addresses educational institutions that receive funds from the U.S. Department of Education. However, it also discusses other materials that may be helpful.
Targeted Topic Training Follow-on grants shall perform Level 1 and 2 training evaluations. Additional guidance on developing and implementing evaluations, and reporting evaluation results will be provided at the Orientation Meeting. The types of training evaluations are described below.
Level 1 – Training Session Reaction Evaluation
Training session reaction evaluations measure how trainees in a training session react to the training including trainees’ perceptions of the quality and usefulness of the training. The results should be used for the improvement of the training program. This assessment can be accomplished through trainee satisfaction surveys, in written or oral format, regarding both the relevancy of the information taught and the teaching style of the instructor. This type of evaluation should be conducted for all training.
Level 2 – Learning Evaluation
Learning evaluations measure the skills, knowledge, or attitude that the trainee retains because of the training. This evaluation could be accomplished for example through pre- and post-assessments, in written or oral format, administered in the training. Alternatively, trainees could be required to perform a new task or complete interactive activities that were taught during the training and the result assessed. This type of evaluation should be conducted for all training.
In addition to the evaluation activities grantees will conduct, the Department of Labor may conduct a separate evaluation of the impacts of training. In accepting grant funding under this program, grantees agree to fully cooperate with and provide any data needed by federally-sponsored evaluation(s) of the training.
Reporting and documentation will be required of grant awardees and as such should be included in the proposed grant activities and accompanying budget. Additional information on the reporting requirements can be found in Administering OSHA Discretionary Grant Programs (TED 03-00-002)
http://www.osha.gov/dte/sharwood/grant_requirements.html.
Orientation Meeting
A mandatory two-day grantee orientation meeting will be conducted in Washington, D.C. All grantees should budget for two staff members, one program and one financial, to attend this meeting.
Program Reports
A quarterly report is required to be submitted to OSHA within 30 days following the end of the fiscal quarter. The report includes a completed OSHA Form 171 and instructions for completing an accompanying narrative for all grant activities conducted.
OSHA Form 171 is a one page fillable spreadsheet and includes documentation of training sessions. Conferences and needs assessments do not count as training sessions. Training sessions for the same group of trainees that are conducted on more than one day are not to be reported until they are completed. To avoid “double-counting,” training numbers for grants with multiple topics will be counted for each time the body of training materials developed under the grant is presented to a group of students; topics will not be counted separately. Sessions are to be reported in the quarter in which they end. A separate OSHA Form 171 is required to be submitted for each type (or tier) of training conducted in a quarter.
Each quarterly progress report should contain information on all work performed during the quarter including training materials development, recruiting, training conducted, training evaluations conducted, and any technical assistance activities, as applicable. The summary for the training evaluations should be an aggregate for type of training conducted and type of evaluation completed during the quarter.
An evaluation of progress on work plan activities is also required for the quarterly report. The purpose of evaluating progress made on work plan activities is to assess how well program activity goals are being met. It involves collecting, analyzing, and using information to determine whether program benchmarks for the quarter were attained and to point out unanticipated developments.
Continuous program activity progress monitoring is recommended. Describe the plan to evaluate the progress in accomplishing grant work activities listed in the application including comparing planned vs. actual accomplishments. Discuss who in the organization is responsible for taking corrective action if plans are not being met.
Training program evaluation (Level 1 and 2) activities shall include a description of the current status of instructor effectiveness, trainee retention of knowledge and skills, and positive impacts of training activities on work practices. To the extent possible, such evaluations shall include quantitative as well as qualitative results.
Financial Reports
Grantees shall electronically submit on DOL E-Grants, the Standard Form (SF-425), Federal Financial Report (FFR) on a quarterly basis during the period which the grant was signed (December 31, March 31, June 30, or September 30). Financial reports are due within 30 days of the end of the reporting period (i.e., by January 30, April 30, July 30, and October 30).
Program Close-out Report
A program close-out report is required to be submitted within 90-days of the end of the grant performance period. The report must summarize all activities conducted under the grant, explain how these activities enabled the grantee to accomplish the goals of the grant, discuss successes and problems encountered, and provide the results of the evaluations. Results and findings from Level 1 and 2 evaluations must be summarized and submitted on an annual basis as a part of the program close-out report. Further guidance for preparing a program close-out report will be provided after receipt of a grant award.
As part of the program close-out report, all applicants are required to include the following:
A written self-certification that grant-funded programs and materials were not provided to ineligible audiences
A written self-certification that any materials developed with grant funds are free from copyright infringements
Financial Close-out Report
A financial close-out report, SF-425, shall be submitted electronically through DOL E-Grants no later than 90 days following completion of the grant period.
Additional documentation of grant activities may be requested throughout the grant cycle. Requests may include, but are not limited to: training sign-in sheets and training evaluation results. Grantees are required to respond to the requests within the time schedule established as part of the request.
For training and other quantifiable activities, estimate how many (e.g., number of advisory committee meetings, classes to be conducted, workers and/or employers to be trained, trainee training contact hours to be provided, evaluation activities, etc.) activities will be accomplished each quarter of the grant (grant quarters match calendar quarters, i.e., January to March, April to June). Quarterly projections should also include all activities related to developing, evaluating, validating, translating newly developed training materials, or researching and identifying existing training materials to be used. Also provide the work plan activity totals for the grant year and substantiate the methodology used to develop the projections.
Grantees are accountable for accomplishing the activities listed in the work plans and meeting quarterly projections. Quarterly projections are used to measure actual performance against the work plan and are reported to the Secretary of Labor at the end of each quarter. Organizations selected for funding may be asked to establish monthly milestones and submit them to the Regional Office.
If the work plan includes a train-the-trainer program, estimate the number of individuals to be trained during the grant period in second tier training by those who received the train-the-trainer training, and estimate the planned trainee training contact hours. To count second tier training numbers, the organization must formally follow-up with the trainers during the grant project performance period to obtain the training documentation records.
Summaries of other relevant organizational experiences, information on prior government grants, resumes of key personnel and/or position descriptions, and signed letters of commitment to the project should be included as attachments. Please limit the number of attachments to essential documents only, with a maximum of 20 pages. Budget information, as requested in the following section, does not count toward the attachment page total.
Acceptable formats for document attachments submitted as a part of a Grants.gov grant application include Microsoft Office, or Adobe Reader (PDF) format.
Applicants must include the following required grant project budget information.
The budget must provide information on the 12-month project performance period.
A Detailed Project Budget that clearly details the costs of performing all of the requirements presented in this funding opportunity announcement. The detailed budget will break out the costs for the 12-month project performance period that is listed in Sections B and C of the SF‑424A Budget Information Form. Applicants are asked to plan for a funding level based on funds needed to perform work plan and administrative activities for the 12-month project performance period. If staff or professional development training is proposed in the budget, the detailed project budget must explain the purpose of the planned training. As outlined in Section V.I.6.b), only staff or professional development trainings taken expressly for the purpose of providing Harwood training to workers is allowable. The applicant’s funding level is not to exceed 90% of the FY 2014 grant award for the 12-month project performance period, as specified in Section III.
The Detailed Project Budget must break out administrative costs separately from programmatic costs for both federal and non-federal funds. Examples of administrative and program costs are identified in Appendix A, Administrative and Program Cost Information. Administrative costs include indirect costs from the costs pool and the cost of activities, materials, meeting close-out requirements as described in Section V.G.3.b)(5)(c), and personnel (e.g., administrative assistants) who support the management and administration of the project, but do not provide direct services to project beneficiaries. Indirect cost charges, which are considered administrative costs, must be supported with a copy of a current approved Indirect Cost Rate Agreement form. Administrative costs cannot exceed 25% of the total grant budget. The project budget should clearly demonstrate the total amount and distribution of funds is sufficient to cover the cost of all major project activities (Section V.G.3.) identified by the applicant in its proposal, and must comply with federal cost principles which can be found in the Uniform Guidance, 2 CFR 200 and 2 CFR 2900.
Applicants are reminded to budget for compliance with the administrative requirements set forth. Copies of all regulations that are referenced in this funding opportunity announcement are available online at no cost at http://www.osha.gov/dte/sharwood/grant_requirements.html. This may also include activities such as a financial audit, if required; project closeout; document preparation (e.g., quarterly progress reports, project documents); and ensuring compliance with procurement and property standards.
Please include a current approved Indirect Cost Rate Agreement if indirect costs are included as part of the application. Indirect costs shall be included under the Administration section of the budget. If the organization does not have a current approved agreement, indirect cost should be estimated. A current approved Indirect Cost Rate Agreement will be required if an organization is awarded a grant and the budget includes indirect costs.
Provide a description of any voluntary non-federal resource contributions to be provided by the applicant, including source of funds, estimated amount, and use of funds consistent with the goals and objectives of the Susan Harwood Training Grant Program. Non-federal resource contributions must meet the same criteria for allowability as other costs incurred and paid with federal funds.
All applicants must be a non-profit organization at the time of application submission and include current evidence of non-profit status from the Internal Revenue Service (IRS) or state must be included. An applicant can show it is a nonprofit organization through any of the following means:
Proof that the Internal Revenue Service currently recognizes the applicant as tax exempt under the Internal Revenue Code, 26 U.S.C. § 501(c)(3);
A statement from a State taxing body or the State Secretary of State certifying that:
The organization is a nonprofit organization operating within the State; and
No part of its net earnings may lawfully benefit any private shareholder or individual;
A certified copy of the applicant’s certificate of incorporation or similar document that clearly establishes the nonprofit status of the applicant; or
Any item described in paragraphs (1) through (3) of this section, if that item applies to a State or national parent organization, together with a statement by the State or national parent organization that the applicant is a local nonprofit affiliate of the organization.
Indian tribes and other tribal organizations can submit equivalent documentation to show evidence of non-profit status. This does not apply to state and local government-supported institutions of higher education.
Grant funds may be spent on the following:
Conducting a needs assessment.
Developing and/or purchasing training and educational materials for use in training.
Conducting training.
Conducting other activities that reach and inform workers and/or employers about workplace occupational safety and health hazards and hazard abatement.
Conducting outreach and recruiting activities to increase the number of workers and/or employers participating in the program.
Grant funds may not be used for the following activities under the terms of the grant program.
Any activity that is inconsistent with the goals and objectives of the OSH Act of 1970.
Activities for the benefit of state and local government employees unless the employees have occupational safety and health responsibilities. Examples of such responsibilities include: occupational safety and health training; safety and health program management; membership on an employer, union or joint safety and health committee; and responsibilities for abatement of unsafe and unhealthful working conditions.
Program activities predominately involving self-employed workers or workplaces that are largely precluded from enforcement action by OSHA under section 4(b)(1) of the Act, codified at 29 U.S.C. 653(b)(1).
Training on topics that do not cover the recognition and prevention of unsafe or unhealthy working conditions. Examples of unallowable topics include: workers’ compensation, first aid, and publication of materials prejudicial to labor or management.
Assisting workers in arbitration cases or other actions against employers, or assisting workers and/or employers in the prosecution of claims against federal, state or local governments.
Duplicating services offered by OSHA, a state under an OSHA-approved State Plan, or consultation programs provided by state designated agencies under section 21(d) of the OSH Act, codified at 29 U.S.C. 670(d)(1).
Conducting any of the OSHA Outreach Training Program classes.
Conducting courses that are presented by the OSHA Training Institute or its OSHA Training Institute Education Centers.
Providing staff development training to grantee employees or contractors unless it is expressly for the purpose of providing Harwood training to workers.
Conducting or providing training through any pre-existing, proprietary, or industry training or certification programs.
Generating membership in the grantee’s and/or partner’s organization. This includes activities to acquaint nonmembers with the benefits of membership, inclusion of membership appeals in materials produced with grant funds, and membership drives.
Reimbursing the cost of lost-time wages paid to trainees while attending grant-funded training.
Providing any compensation or stipends to trainees prior to, during, or after attending grant-funded training for any grant related activities.
Providing food and beverages.
Exceeding 25% of the total grant budget for administrative costs. Indirect costs are considered to be administrative costs.
Duplicating services of other federal and/or state agencies.
Proposing training required by other federal and/or state agencies.
While the activities described above may be part of an organization’s regular programs, the costs of these activities cannot be paid for by grant funds, whether the funds are from non-federal matching resources or from the federally funded portion of the grant.
All proposed costs must be necessary, reasonable, and in accordance with federal guidelines. Determinations of allowable costs will be made in accordance with the Cost Principles found in the Uniform Guidance 2 CFR 200 and in 2 CFR 2900. Disallowed costs are those charges to a grant that the grantor agency or its representative determines to not be allowed in accordance with the applicable federal cost principles or other conditions contained in the grant.
No applicant at any time will be entitled to reimbursement of pre-award costs.
The cost per trainee must be less than $500 and the cost per training hour must not exceed $125. Estimates for cost per trainee and cost per training hour should be clearly identified in the grant application. Calculations should be based on the total projected number trained and total contact hours as presented in the applicant’s work plan (Section V.G.3.b)(3)(g)). Please use the following formulas to calculate these costs:
Cost per trainee = total grant cost (include federal and non-federal) / the total projected number trained
Cost per training hour = total grant cost (include federal and non-federal) / the total projected number of contact hours for all training
The intent of the Susan Harwood Training Grant Program is to provide training and/or training products that support additional training. Applications focusing on training and training and educational materials development will receive higher consideration than those containing capital equipment purchases. Capital equipment purchases are those items that are required to be depreciated for tax purposes.
In keeping with the policies outlined in Executive Orders 13256, 12928, 13230, and 13021 as amended, the grantee is strongly encouraged to provide subcontracting opportunities to Historically Black Colleges and Universities, Hispanic Serving Institutions, and Tribal Colleges and Universities.
The deadline date for receipt of applications is Tuesday, June 2, 2015. Applications must be received by 11:59 p.m., ET, on the closing date at http://www.grants.gov. Any application received after the deadline will not be accepted.
OSHA strongly encourages organizations to submit the grant application in sufficient time to ensure that the application has been received and successfully validated by Grants.gov by the application deadline.
Applications for Susan Harwood grants under this funding opportunity announcement must be submitted electronically using the government-wide Grants.gov Apply site at: http://www.grants.gov. Through this site, organizations will be able to download a copy of the application package, complete it offline, and then upload and submit the full application. Acceptable formats for document attachments submitted as a part of a Grants.gov grant application include Microsoft Office and the Adobe Reader (PDF) format. The Susan Harwood grant application package at: http://www.grants.gov contains a menu of “Mandatory Documents” that must be completed and submitted online. The menu of “Mandatory Documents” can only be located after opening the grant package. Applications sent by mail or other delivery services, email, telegram, or facsimile (FAX) will not be accepted. Applications that do not meet all of the conditions set forth in this notice may be considered non-viable and may not be given further consideration as specified in Section IV.E.
For applicants with prior experience using Grants.gov, registration must be accurate and up-to-date in Grants.gov and with the System for Award Management (SAM) prior to submitting an application. If the organization is already registered with Grants.gov and there have been any changes to the organization users, such as the E-Biz POC or AORs, please be sure the necessary updates are made with Grants.gov to prevent a delay in submission of the electronic application. Please note that registered organizations must also renew the status with SAM at least every 12 months and ensure the information is kept current. This process takes a minimum of five days to complete. This additional time should be factored into an applicant’s plans for electronic application submission to avoid unexpected delays that could result in the rejection of the application.
The Grants.gov Web site has several tools and documents available online to assist organizations with the Grants.gov process. Further information is available from the Applicant Resources section at: http://www.grants.gov/web/grants/applicants/applicant-resources.html. Applicants are strongly encouraged to review the Grants.gov user guide. The link to the guide is located under “Applicant Resources,” just click on Grants.gov Applicant User Guide (pdf). An Organization Registration Checklist is also available in the Applicant Resources section.
Authorized Organization Representative (AOR) Authorization. Prior to submitting grant application packages, representatives of the organization need to register to submit on behalf of the organization. The organization’s E-Business Point of Contact (E-Biz POC), identified during the System for Award Management (SAM) registration process must authorize someone to become an AOR. This safeguards the organization from individuals who may attempt to submit grant application packages without permission. Only one E-Biz POC is assigned for each of an organization’s DUNS number. If the organization only has one DUNS number, then there will be only one E-Biz POC for the organization.
NOTE: In some organizations, a person may serve as both an E-Biz POC and an AOR. In this case the same individual will need to perform the step of approving themselves as an AOR. E-Biz POC’s who want to submit applications through Grants.gov, will need to register with Grants.gov as an AOR, using an alternate email than the one used in correlation with the E-Biz POC, to authorize themselves as an AOR.
After an AOR registers with Grants.gov, the E-Biz POC will have to approve the individual who registered as the AOR.
An application submitted through Grants.gov constitutes a submission as an electronically signed application. The registration and account creation with Grants.gov, with E‐Biz POC approval, establishes an AOR. When an application is submitted through Grants.gov, the name of the AOR on file will be inserted into the signature line of the application. You must register the individual who is able to make legally binding commitments for your organization as the AOR; this step is often missed and it is crucial for valid submissions.
If there are questions regarding the process for updating the organization users or submitting the application through Grants.gov, or problems are experienced with electronic submissions, contact the Grants Program Management Office via one of the methods below:
E-mail at: [email protected].
Telephone the Grants.gov Contact Center Phone: 1‑800‑518-4726. The Contact Center is open 24 hours a day, 7 days a week. The Contact Center is closed on federal holidays.
When contacting the Grants Program Management Office, the following information will help expedite the inquiry.
Funding Opportunity Number (FON)
Name of Agency to which the Organization is Applying
Specific Area of Concern
If applying online poses a hardship, applicants must contact the OSHA Directorate of Training and Education office listed in the announcement at least four weeks prior to the application deadline date of 11:59 p.m., ET, Tuesday, June 2, 2015, to speak to a representative who can provide assistance to ensure applications are submitted online by the closing date. Requests for extensions to the grant application deadline will not be granted.
Applicants are limited to using the following characters in all attachment file names: A-Z, a-z, 0-9, underscore (_), hyphen (-), parenthesis (()), curly brackets ({}), square brackets ([]), tilde (~), exclamation point (!), comma (,), dollar sign ($), percent sign (%), plus sign (+), equal sign (=), space, and period. File attachment names should be no longer than 50 characters to avoid submission and processing errors.
While Grants.gov may accept more characters, DOL E-Grants will not accept characters other than what is listed. Use the appropriate characters to ensure that OSHA staff can view the file attachments.
The Susan Harwood Training Grant Program is not subject to Executive Order 12372 Intergovernmental Review of Federal Programs.
Grant applications will be reviewed by OSHA staff. Past grant performance will be considered during the review process. OSHA Regional personnel will review all applications to determine whether all required proposal elements are present and clearly identifiable. Applicants may be requested to clarify or provide additional supporting information during the Regional personnel review period. The results of the grant reviews will be presented to the Assistant Secretary of OSHA, who will make the selection of organizations to be awarded grants. The Assistant Secretary determination for award under this funding opportunity announcement is final.
Organizations selected as grant recipients will be notified by a representative of the Assistant Secretary, no later than September 30, 2015. An applicant whose proposal is not selected will be notified in writing.
Notice that an organization has been selected as a grant recipient does not constitute approval of the grant application as submitted. Before the actual grant award, OSHA will enter into negotiations concerning such items as program components, staffing and funding levels, and administrative systems. If the negotiations do not result in an acceptable submittal, the Assistant Secretary reserves the right to terminate the negotiation and decline to fund the proposal. All revised documents must be received no later than October 15, 2015.
The government may elect to award the grant(s) with or without negotiations with the applicant. Should a grant be awarded without negotiations, the award will be based on the applicant’s signature on the SF-424, including electronic signature via E-Authentication on http://www.grants.gov, which constitutes a binding offer by the applicant.
NOTE: Except as specifically provided, OSHA’s acceptance of a proposal and an award of federal funds to sponsor any program(s) does not provide a waiver of any grant requirement or procedures. For example, if an application identifies a specific sub-contractor to provide services, the OSHA award does not provide the justification or basis to sole-source the procurement (i.e., to avoid competition).
All grantees, including faith-based organizations, will be subject to applicable federal laws and regulations (including provisions of appropriations law) and the applicable OMB Uniform Guidance. Grantees are required to cooperate with all federal, state, and local requirements. The grant award(s) awarded under this funding opportunity announcement will be subject to the following administrative standards and provisions, as applicable to the particular grantee:
29 CFR 2, Subpart D, new equal treatment regulations
29 CFR Parts 31, 32, 35 and 36 as applicable
29 CFR 93, restrictions on lobbying
CRF 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), which covers grant requirements for nonprofit organizations, including universities and hospitals. (http://www.gpo.gov/fdsys/pkg/FR-2013-12-26/pdf/2013-30465.pdf)
2 CFR 2900, Department of Labor exceptions to the OMB Uniform Guidance. (http://www.gpo.gov/fdsys/pkg/FR-2014-12-19/pdf/2014-28697.pdf)
General Terms and Conditions of Award – See the following link: http://www.osha.gov/dte/sharwood/grant_requirements.html
Federal Funding Accountability and Transparency Act of 2006 or Transparency Act – Public Law 109-282, as amended by section 6202(a) of Public Law 110-252 (31 U.S.C. 6101). (http://edocket.access.gpo.gov/2010/pdf/2010-22705.pdf)
2 CFR 25, Financial Assistance Use of Universal Identifier. (http://edocket.access.gpo.gov/2010/pdf/2010-22706.pdf)
2 CFR 170, Reporting Subaward and Executive Compensation Information.
Grantees are required by Departmental regulations to submit program and financial reports each calendar quarter. All quarterly reports are due no later than 30 days after the end of the fiscal quarter. In addition, grantees are required to submit grant program and financial closeout reports within 90 days after the grant termination or expiration date. Detailed information on the report requirements are included in Section V.G.3.b)(5).
OSHA has a lending program that circulates grant‑produced audiovisual materials. Audiovisual materials produced by the grantee as a part of its grant program may be included in this lending program. Two copies of all final product materials produced by grantees must be provided to OSHA in bound and clearly labeled hard copies as well as two copies in a digital format (CD Rom/DVD/flash drive), per Section V.G.3.b)(1)(f) for possible publication on the Internet by OSHA. All final product materials must be submitted following guidelines established in Appendix B, Procedures for Submitting Electronic Copies of Grant-Funded Materials.
As stated in 2 CFR 200.315, DOL reserves a royalty-free, nonexclusive and irrevocable right to reproduce, publish, or otherwise use for federal purposes any work produced under a grant, and to authorize others to do so. Applicants should note that grantees must agree to provide DOL a paid-up, nonexclusive, and irrevocable license to reproduce, publish, or otherwise use for federal purposes all products developed, or for which ownership was purchased, under an award including, but not limited to, curricula, training models, technical assistance products, and any related materials, and to authorize the others to do so. Such uses include, but are not limited to, the right to modify and distribute such products worldwide by any means, electronic or otherwise.
When issuing statements, press releases, requests for proposals, bid solicitations, and other documents describing projects or programs funded in whole or in part with federal money, all grantees receiving federal funds must clearly state:
the percentage of the total costs of the program or project that will be financed with federal money;
the dollar amount of federal financial assistance for the project or program; and
the percentage and dollar amount of the total costs of the project or program that will be financed by non-governmental sources.
Use of the DOL or OSHA Logo
Neither the DOL nor OSHA logo may be applied to any grant products developed with grant funds.
Appendix A – Administrative and Program Cost Information
As described in the funding opportunity announcement (FOA), the Detailed Project Budget must break out administrative costs separately from programmatic costs for both federal and non-federal funds. Administrative costs include indirect costs from the costs pool and the cost of activities, materials, meeting close-out requirements, and personnel (e.g., administrative assistants) who support the management and administration of the project, but do not provide direct services to project beneficiaries. Indirect cost charges, which are considered administrative costs, must be supported with a copy of a current approved Indirect Cost Rate Agreement form. Administrative costs cannot exceed 25% of the total grant budget.
ADMINISTRATIVE COSTS
General administrative functions and coordination of functions:
accounting
audits
budgeting
financial and cash management
general legal services functions
payroll functions
personnel management
procurement
property management
purchasing
report preparation
review resolution
development of systems and procedures for administrative functions
Costs of goods and services required for administrative functions of the program, including goods and services such as:
advertising and outreach services targeted to the general public
internet services
office supplies
postage
rental and maintenance of office space
rental/leasing and maintenance of equipment (copiers, printers, etc.)
utilities
Travel costs incurred for official business in carrying out administrative activities or the overall management of the grant.
The purchase, systems development, and operating costs of information systems related to administrative functions. For example:
personnel
procurement
purchasing
property management
accounting and payroll systems
The portion of awards to subrecipients or vendors that is for the performance of administrative functions.
PROGRAM COSTS
All costs incurred directly for functions and training activities including salaries for personnel providing direct training to workers and employers.
The purchase, systems development, and operating costs (e.g. data entry costs) of the following information systems are charged as a program cost:
Tracking or monitoring of participant information including basic worker information, employer information, and other statistical information relevant to program evaluations
Performance and program cost information on training services and activities
Costs of goods and services required for direct program functions, including goods and services such as:
advertising and outreach services specific to recruiting the target audience to attend training
training supplies, including local reproduction
rental or purchase of training equipment
rental and maintenance of training space
Travel costs incurred for official business in carrying out training activities.
The portion of awards to subrecipients or vendors that is for the performance of program functions.
The portion of indirect costs determined as a proportionate share of the indirect costs in the indirect cost pool which are the costs of program functions, not administrative functions (see indirect costs below).
SHARED ADMINISTRATIVE AND PROGRAM COSTS
Personnel and related non-personnel costs of staff that perform both administrative functions and programmatic services are to be allocated as administrative costs or program to the benefitting cost objectives/categories based on documented distributions of actual time worked and other equitable cost allocation methods.
INDIRECT COSTS
As specified in the Uniform Guidance 2 CFR 200, indirect costs are those that have been incurred for common or joint purpose benefitting more than one cost objective and not be readily assignable with a particular final cost objective. An indirect cost rate is required when an organization operates under more than one grant or other activity, whether federally-assisted or not.
Indirect costs represent the expenses of doing business that are not readily identified with a particular grant, contract, project function or activity, but are necessary for the general operation of the organization and the conduct of activities it performs.
An indirect cost rate is a mechanism for determining fairly and conveniently within the boundaries of sound administrative principle, what proportions of organization administration costs each program should bear.
Indirect costs are only allowable with an approved Indirect Cost Rate Agreement (ICRA). ICRAs are negotiated and approved by the cognizant federal agency. An agreement from any federal agency is applicable to all federal grant programs. The ICRA will include a rate (percentage) and a base. The allowable amount of indirect costs is simply the rate times the base. Rates and bases depend on the size and number of cost pools, and organization structure.
Appendix B – Procedures for Submitting Electronic Copies of Grant-Funded Materials
As described in the funding opportunity announcement (FOA), any materials (training, marketing, etc.) distributed during the grant period are required to be reviewed by OSHA. In addition, electronic and paper copies are required to be submitted by the end of the grant period. The purpose of the electronic copies is to be able to share the materials to the general public via the OSHA Web site. These instructions were developed to standardize submittal procedures for the grant-funded training materials.
Material Requirements. When submitting grant-funded training materials make a note of the following:
The word “draft” must not appear on any materials (print or electronic) submitted to OSHA as the final version. If the materials were produced in a non-English language, a final English version must also be submitted.
Training materials must be generic and appropriate for all audiences. References to training of specific groups, members of a group, or individuals should not be included in the final submittal. This includes personal information such as the instructor names, addresses, cell phone numbers, email addresses, etc.
Promotional materials can include the grantee organizational information including phone numbers, email addresses, etc.
If a test is included, ensure that the test and test answers are provided.
In all circumstances, all approved grant-funded materials developed by a grantee shall contain the following disclaimer:
This material was produced under grant number _____________ from the Occupational Safety and Health Administration, U.S. Department of Labor. It does not necessarily reflect the views or policies of the U.S. Department of Labor, nor does mention of trade names, commercial products, or organizations imply endorsement by the U.S. Government.
Required Programs: Grant-funded training materials must be provided in a format that is widely accessible to the public. Microsoft Office 2003, 2007, or 2010 formats, as indicated below, meet this requirement. Currently there is no preferred program for providing media files.
Word Files: Manuals and other print materials must be submitted as Word 2003, 2007, or 2010 documents.
PowerPoint Files:
Must be submitted as .ppt or .pptx files. “Show” format is not acceptable.
Photographs and other images must be compressed in JPEG format.
If the presentation includes linked or embedded audio or video files, two copies of the presentation must be provided. One copy must not contain any linked or embedded files.
Presenter notes or a transcript of the presenter notes must be included.
Media Files (Only for online courses): Must be ADA compliant.
Images such as photographs must have descriptive captions.
Audio files must have transcripts.
Video files must be captioned and have transcripts.
Submitting Materials. All grant-funded training materials must be submitted in both print and electronic format. Review the FOA for the appropriate number of copies that are required to be submitted. Please note the following:
A list of materials being submitted by the grantee should be provided.
Printed documents must be submitted in a bound format, for example spiral-bound or 3-ring binder.
Produced materials that are not practical for mailing, banners, etc. should be photographed and photo included with the submitted materials.
All electronic files of grant-funded materials must be test-based. Electronic files are restricted to those smaller than 15MB. This may require the grantee to split files.
The CD, DVD, or USB flash drive must be clearly labeled with the grantee’s organization and the grant number (SH-XXXXX-SHX), where XXXXX is the 5-digit grant number and the last X is the last digit of the fiscal year for which the grant was awarded.
The electronic files on the CD, DVD, or USB flash drive must be clearly labeled by type of material (examples):
Instructor Manual
Student Manual
Pre-Test
Post-Test
Evaluation Form
Check the CD, DVD, or USB flash drive before sending to ensure that all of the files will open.
Check the CD, DVD, or USB flash drive before sending to ensure that all grant-funded materials are included.
Files should be provided in a readily usable format. Therefore, files must not be password protected, “read only” format, or encrypted.
___________________
Authority: Section 21 of the Occupational Safety and Health Act of 1970. (29 U.S.C. 670), Public Law 111-117, and Public Law 112-10.
OMB Approval No.: 1225-0086
Expiration Date: 01/31/2016
OFFICE OF MANAGEMENT AND BUDGET INFORMATION COLLECTION REQUIREMENTS.
This FOA requests information from applicants. This collection of information is approved under OMB Control No. 1225-0086 (Expires 01/31/2016).
In accordance with the Paperwork Reduction Act of 1995, no person is required to respond to a collection of information unless such collection displays a valid OMB control number. Public reporting burden for the grant application is estimated to average 56 hours per response, for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimated or any other aspect of this collection of information, including suggestions for reducing this burden, to the OMB Desk Officer for OSHA, Office of Management and Budget, Room 10235, Washington DC 20503, electronically to Jason Rasmussen at [email protected] or the Grant Officer, Elizabeth Norris at [email protected] or by mail to Jason Rasmussen, 2020 S. Arlington Heights Road, Arlington Heights, Illinois 60005.
This information is being collected for the purpose of awarding a grant. Unless otherwise specifically noted in this announcement, information submitted in the respondent’s application is not considered to be confidential.
Billing Code 4510-26-P
1 OMB Memorandum 07-16 and 06-19. GAO Report 08-536, Privacy: Alternatives Exist for Enhancing Protection of Personally Identifiable Information, May 2008, http://www.gao.gov/new.items/d08536.pdf.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Billing Code: |
| Author | Wanderski, Heather - OSHA |
| File Modified | 0000-00-00 |
| File Created | 2021-01-30 |